Various regulatory agencies are working to protect the privacy of online users, particularly children, by imposing certain guidelines regarding the acquisition and storage of speech data. For example, the FTC's recent implementation of the Children's Online Privacy and Protection Act (COPPA) concerns itself in part with children under 13 years old. Changes to the Act may require that audio files that contain a child's voice be considered “personal information” deserving of special protection. Companies which provide child-oriented applications, such as entertainment applications, may need to gather consent from parents before letting children use their service, particularly where the service acquires and processes personal information in the course of entertaining the child audience.
Legislation, such as COPPA, may require that consent be acquired in one of two categories: “rigorous” and “mild”. Rigorous forms of consent may include, e.g., processing a credit card payment, maintaining a call center for parents to contact, requiring a parent to print, sign, and mail a physical approval form, etc. Mild forms of consent may include, e.g., “email plus” activities. COPPA's “email plus” method allows a company to request (in the direct notice to the parent) that the parent provide consent in an email message. For various business and growth reasons, including potentially offering customers a free trial to their services, many organizations may prefer to gather consent via a mild method, such as the “email plus” method.
Legislation such as COPPA is also concerned with the “disclosure” of personal information, and may compel companies to use the more rigorous forms of consent when personal information is shared with third parties. However, there is an important exception (16 C.F.R. 312.2. “disclosure”0.1) that allows companies to implement consent via “email plus” as long as a third party provider is only using the information for supporting the internal operations of the company's online service.
Accordingly, there exists a need for systems and methods which comply with the legislative changes, while providing the functionality necessary to perform certain interactive operations.